On June 13, 2012, Hogan Lovells Partners Thomas L. McGovern and Todd R. Overman, both with our Government Contracts Practice, published a Client Alert entitled, “DOD Voluntary Cyber Security Program Requirements May Limit Participation Opportunities For Some Government Contractors.” The Client Alert discusses the practical implications for government contractors of the Department of Defense’s interim final rule entitled, “Defense Industrial Base (DIB) Voluntary Cyber Security and Information Assurance (CS/IA) Activities.” Tom McGovern and Todd Overman observe:
The program addresses the increased targeting by hackers of DOD systems and defense contractors. The voluntary, four-year-old program originally included approximately forty contractors and the rule hopes to expand the program to all qualified defense contractors. However, the burdensome participation requirements may limit the scope of involvement by certain government contractors and may in fact deter some contractors from participating altogether, especially contractors operating under Foreign Ownership, Control or Influence (FOCI).
You can view a copy of the Client Alert by clicking here.